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Privacy Policy

1010data- Privacy and Cookies Policy

Updated April 2019.
This policy covers how 1010data, Inc. and its affiliates (“1010data”, “we”, “us”, or “our”) treat data and information collected and received through our websites (“Sites”) and big data products and services (“Services”).

Scope of this Policy

This policy applies only to information collected and received by us through access and use of the Services and/or Sites and does not apply to any other information collected by us through other means. Further, this policy does not cover the activities of third parties.
It is your responsibility to read and understand this policy. By using our Services and/or Sites, you are agreeing and consenting to the practices described in this policy. If you do not agree to all of this policy and do not wish to be bound by it, you should not use our Services or Sites.
This policy may change from time to time so please check back here frequently.

This policy explains the following:
  • What personal information we collect and receive
  • How we use personal information
  • How we disclose your information, including personal information
  • How we secure and store your information
  • Choices about receiving marketing messages
  • Cookies and “do not track”
  • Other websites
  • California privacy rights
  • Access to and accuracy of personal information
  • Privacy Shield
  • Users in the European Economic Area (EEA) and Switzerland
  • How to contact us

What personal information we collect and receive
Personal information is generally understood to include information that can be used to identify, distinguish, or trace a natural person’s identity, either alone or when combined with other information. Personal information may include the name, address, zip code, e-mail address, telephone number(s), Internet Protocol (IP) address, and other information collected from or about a natural person or the device he/she uses, such as usage, location or contacts, data or statistics, and other aggregated information that can be linked back to a specific person. Personal information may also include more sensitive information such as driver’s license number, other government issued id, credit, debit, bank or payment card number or account information, other financial account information, and social security number (“Sensitive Information”). Other than to fulfill your payment obligations to us, we do not seek or collect Sensitive Information and advise you to use caution in choosing what information you upload to our Services, especially Sensitive Information.
The personal information we collect and receive may include the following:
  • Personal information you provide when you register with our Services (including for trial access), request information from us, and when we perform work for you.
    • This may include: your name, industry, organization name, job, contact information, such as e-mail address, phone number, and shipping address, payment information, such as a credit or debit card number, and password for your account access.
  • Personal information that you upload into our Services.
  • Information related to transactions requested or completed through the Sites.
  • Communications with us (whether in writing, by email, or by telephone).
Whenever you visit the Sites or use our Services, we also receive and record information on our server logs from your browser, including your computer or mobile device’s operating system type and version, browser type and language, your Internet Protocol (IP) address, and geographic areas derived from your IP address, our cookie information, file information, time-stamped logs regarding access times and duration of visits, the websites you visited before coming to the Sites, and other usage data relating to your activities on our Sites, including the pages you request. We may relate this information to the personal information you provide for purposes described in this policy.
Certain third parties, including analytics companies, advertisers, and ad networks, may also automatically collect information about you through our Sites, using cookies, Web beacons, device identifiers, and similar technologies, including personally identifiable information about your online activities over time and across different websites, devices, online channels, and applications.

 

How we use Personal Information

We use personal information collected through our Sites or through use of our Services for purposes described in this policy and the Terms of Use you enter into with us prior to using our Services. For example, we may use your information to:
  • Provide and deliver you access to our Services after you’ve registered, paid for, or requested such access;
  • Provide software updates and communicate with you about our Services;
  • Operate and improve our internal operations, systems, products, Sites and Services;
  • Understand you and your preferences to enhance your experience;
  • Respond to your comments and questions and provide customer service;
  • Send you Service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • Communicate with you about promotions, upcoming events, and news about our Services;
  • Link or combine information about you with other personal information we get from third parties, to help understand our users’ needs and provide our users with better and more personalized service;
  • Enforce our terms and conditions or protect our business, third party service providers, or users; and
  • Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.
We may also contact you about your registration details, to manage any account or subscription you have with us, or to provide customer service, even if you have opted-out of or declined to consent to receive promotional emails. We may also contact you to inform you of revisions to this policy. We also may use location data, IP address or device identification number, and other information from and about devices, browsers, operating systems, manners of connecting to the internet, internet service providers or wireless carriers, or other information related to use of the Services or the Sites in depersonalized form to improve our Services or Sites and occasionally for other internal purposes.

How we disclose your information, including personal information

We do not rent, sell, or share the information that you upload to our Services or the Sites with non-affiliated third-parties, except that information may be disclosed under the following circumstances:

  • When we have your permission including when you choose to share information on any public portions of the Sites such as our online forums.
  • We may provide the personal information you provided to third party service providers that provide us with services, but only for the purpose of and to the extent necessary to provide those services. For example, we may transfer your credit/debit card or payment account information to third party service providers who will securely process your payments. We do not maintain any of your credit/debit card or payment account information.
    • These companies may use your personal information to help us provide the Services you requested and/or to communicate with you. While we may seek to require third-party service providers to follow appropriate privacy practices and will not authorize them to use your information except for the express purpose for which it is provided, we do not bear any responsibility for any actions, practices, or policies of third parties, except as required under the Privacy Shield Frameworks or other law.
  • We may share, transfer or disclose some or all of your information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or other proceeding involving the sale, transfer, divestiture, or assignment of all or a portion of our business or assets to a different entity.
  • We may disclose personal information to comply with laws or in response to legal process, for example, in response to a court order or a subpoena. We also may disclose personal information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, verify, prevent, enforce compliance with, or take action regarding: illegal or suspected illegal activities; suspected fraud; situations involving potential threats to the physical safety of any person; protection of the rights and property of 1010data, our Sites and Services, and our agents, customers, or others; or violations or suspected violations of our agreements and policies or as otherwise required or permitted by law or consistent with legal requirements.
  • Finally, we may also share aggregated, anonymized, or statistical information about you, including demographic data, with others for a variety of purposes, including for their own uses (e.g., for improving their products and services in connection with our Services or for other purposes that do include identification of individuals).

How we secure and store your information
We have put in place reasonable and appropriate physical, electronic, and organizational procedures to help safeguard information collected or received through our Services and Sites and to protect your information from unauthorized or unlawful use, as well as the accidental loss, destruction, or damage while under our control.
We are a global company with affiliates, varied business processes, management structures, and technical systems that cross borders. Information collected by our Services and Sites, may be stored on your computers, on your mobile devices, or on servers controlled by us, and this information may be transferred to, accessed from, or stored and processed in, the United States or other countries which may not have data privacy laws that provide protections equivalent to those provided in your home country. However, we will protect all personal information we obtain in accordance with this policy and take reasonable steps to ensure that it is treated lawfully. We will only retain personal information for as long as needed to fulfill legitimate business purposes, including the purposes outlined in this policy, or for a period of time specifically required or allowed by applicable regulations or laws. Note that upon termination of your Services account(s), we will maintain the information uploaded to the Services for six (6) months, to enable a prompt and efficient re-engagement of your account, should you decide to do so.
While we take reasonable steps described above to secure your information, because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the information that you send to us or the security of our servers, networks or databases, and by using our Services and/or Sites you agree to assume all risk in connection with your personal information and the information you upload thereto. We are not responsible for any loss of such information. To help protect your personal information and the information you upload to the Services, please use a strong password, do not use the same passwords to access your Services accounts that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services.
In the unlikely event that we believe the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, push notification, or otherwise.

Choices about receiving marketing messages
We give you choices regarding the collection, use, and sharing of your personal information collected through our Services and/or Sites. When you register or respond to one of our communications or offers, we may ask you to make choices about receiving further marketing communications from us. In addition, should you wish to stop receiving marketing communications directly from us, you will be able to unsubscribe or opt-out, or you can contact us as described at the end of this policy and we will make the changes for you. Please remember to include your full name and email address in order
that we may make the changes that you request. To opt out of communications provided by third parties, you may need to opt out or change your privacy settings with the third party. For example, if you no longer wish to receive marketing communications from us through your social media account, you can modify your privacy settings for your social media account to change or limit the information shared.

Cookies and “do not track”
“Cookies” are pieces of information that an online service transfers to your hard drive to store and sometimes track information about your device. “First Party Cookies” are cookies that we set to collect information through the Sites or within the Services for our use. “Third Party Cookies” are cookies that are set by third parties to collect information through the Sites on our behalf; such third parties may collect information for their own purposes too. We do not necessarily control or influence the specific types of information that third parties may collect through the Sites. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. You are not obliged to accept cookies and you can adjust your browser’s setting to prevent it from accepting cookies on your device – go to www.allaboutcookies.org for instructions on how to disable cookies. However, you may not be able to take full advantage of our Services or Sites if you do so.

First Party Cookies
  • We may collect information about your device using first-party cookies, including, where available, your IP address, operating system, and browser type for system administration.
  • The Services and the Sites may also use first-party cookies, for example, to:
    • Gather customer journey information to fulfill your requests;
    • Provide privacy protection when you visit the Services and Sites;
    • Store details of your marketing preferences to improve and enhance your use of our Services and Sites;
    • Evaluate our advertising and promotional effectiveness;
    • Detect if a service has already been offered to you so that we don’t ask you again.

Third Party Cookies
Ad network providers, advertisers, sponsors, traffic measurement services, and other third parties may set cookies through the Platform and Sites and access your device if you choose to have cookies enabled in your browser or they may otherwise have access to information about your device that does not directly identify you. These third party cookies are set to, among other things, help deliver advertisements that you might be interested in, to prevent you from seeing the same advertisements
too many times and to conduct research regarding the usefulness of certain advertisements to you. Note that any images (or any other parts of a web page) served by third parties in association with third-party cookies may serve as web beacons, which enable third parties to carry out the previously described activities. Third party cookies and web beacons are governed by each third party’s specific privacy policy, not this one. If you do not want the services that third-party cookies provide, you may be able to opt-out by visiting http://youronlinechoices.eu, http://www.aboutads.info, and/or http://www.networkadvertising.org.

Do Not Track
As discussed above, you may opt out of third-party cookies at any time. However, we do not currently support any browser-based Do Not Track (DNT) settings or participate in any DNT frameworks, and we do not assign any meaning to any potential DNT track signals you may send or alter any of our data collection or use practices in response to such signals.

Other websites
This policy applies only to our Services and Sites. There may be links on our Sites to third party websites over which we have no control and when you click on advertisements or links you will leave our Sites and go to another website and thereafter it is that third party’s website whose privacy policy will apply. A third party’s privacy practices may differ from ours.
We accept no responsibility or liability for any third party practices on third party websites and advise you to carefully read third party privacy statements prior to the use of any third party website.

California privacy rights
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. To make such a request, please contact us as described and the end of this policy.

Access to and accuracy of personal information
If you have any questions or concerns regarding our collection, use or disclosure of your personal information or if you wish to access, correct, or delete the personal information held by us, you should contact us in writing using the information provided below. As may be provided under applicable law, we will provide you with copies of your personal information; we will require a nominal administration charge of US$10 for all individuals located outside the European Economic Area. We are also obliged to request that you provide us with identification so that we can be certain that you are entitled to receive the requested data.
Please help us to keep our records of your personal information accurate and up-to-date. If you believe any information we’re holding about you is inaccurate, incomplete, or outdated, please contact us using the information below so that we may work with you to correct it.

Privacy Shield
1010Data Inc. and its affiliates (including 1010Data Services LLC; 1010Data Financial Services LLC; 1010Data Retail Solutions LLC; 1010Data Solutions LLC; 1010Data Global Telecom Solutions LLC; 1010Data Online Data Insights LLC; and 1010Data Holdings Corp.) comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (and Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. 1010data has certified that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

As a participant in the EU-U.S. Privacy Shield, 1010data is subject to the investigatory and enforcement powers of the Federal Trade Commission. Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to complaint@1010data.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for Sensitive Information, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to complaint@1010data.com.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Our accountability for personal information we receive in the United States under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal information on our behalf do so in a  manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us by email at complaint@1010data.com or via post at:
1010data, Inc.
750 Third Avenue Fourth Floor
New York, NY 10017

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Users in the European Economic Area (EEA) and Switzerland
If you are a resident of the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Sites and Services.
Purposes of processing and legal basis for processing: We process personal data consistent with our disclosures in this policy. We process personal data on the following legal bases: (1) with your consent; (2)
as necessary to perform our agreement to provide Services (such as when you register for an account to use the Services and accept our license agreement); and (3) as necessary for our legitimate interests in providing the Sites and Services where those interests do not override your fundamental rights and freedoms related to data privacy.

Transfers: Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards, such as Privacy Shield certification (described above).

Individual Rights: You are entitled to the rights under Chapter III of the EU General Data Protection Regulation or Section 2 of the Swiss Federal Act on Data Protection with respect to the processing of your personal data when we act as a data controller, which include the right to access and rectify your personal data and to request erasure of your personal data. To exercise these rights, contact us at complaint@1010data.com. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. You may also have the right to lodge a data protection complaint with your local Supervisory Authority.

How to contact us or opt -out
If you do not understand or accept this policy or wish to contact us concerning any matter relating to your personal information, including if you want to opt-out of us disclosing your personal information to third parties for their direct marketing purposes, then please email privacy@1010data.com or write to us at the address below.
We are committed to resolving complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this policy should first contact us via email at complaint@1010data.com
or write to us at:
Privacy and Cookie Policy Inquiries
1010data, Inc.
750 Third Avenue Fourth Floor
New
York, NY 10017